“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.
“Data Controller” means TwoCrown, the company responsible for the use and processing of Personal Information.
“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and TwoCrown.
“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
WHAT TYPES OF INFORMATION DOES TWOCROWN GATHER ABOUT ITS USERS?
Information that you give us
We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:
- fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;
- access or use the Platform, such as to make or accept bookings, pay for Accommodations, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;
- link your account on a Third-Party site (e.g. Facebook) to your TwoCrown Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorised by you;
- communicate with TwoCrown; and share information with another Member.
Information we get from your use of our Platform
We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services.
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with TwoCrown or logged in to your TwoCrown Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
Cookies and other Tracking Technologies
While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for TwoCrown services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.
Third-Party social plugins
Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.
As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.
HOW TWOCROWN USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We use, store and process information about you for the following general purposes:
- to enable you to access and use the Platform;
- to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the Booking process;
- to operate, protect, improve and optimise the Platform, TwoCrown’s business, and our users’ experience, such as to perform analytics, conduct research, personalise or otherwise customise your experience, and to provide customer service;
- to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about TwoCrown, our services, or general promotions for partner campaigns and services.
How TwoCrown Uses and Processes User Communications
We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyse your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyse messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyse messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyse your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that TwoCrown, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyse, and store your communications, whether done manually or through automated means.
WHEN TWOCROWN DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOMIMPORTANT:
When you use the Platform, your data may be sent to other countries.We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
Your Personal Information may be disclosed as follows:
Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.
Your public Listing page will always include some minimum information such as the city and local vicinity where the Accommodation is located, your listing description, your calendar availability, and any additional information you share with other Members. The Platform may also display the Accommodation’s approximate geographic location on a map, such that a user can see the general area of the Accommodation.
The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public Listing pages, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.
When you submit a request to book an Accommodation, your full name, and the full name of any confirmed Guests staying with you, and other Personal Information you agree to pass through to the Host(s) will become visible to the Host(s) of any Listing you Book or request to Book. We may also disclose parts of your public profile; your public Wish List; other Member reviews of you; and any additional information you share with other Members. In addition, if you agree to be contacted by the Host(s) by phone before your request to Book is accepted, and the Host(s) decides to do so, we will not share your phone number unless there is a confirmed booking; if there is a confirmed booking, your phone number will become visible to the Host(s)/Guest, who may call you directly.
When your request to book an Accommodation is accepted by the Host(s) or when a Guest books your Accommodation, we will disclose some of your Personal Information to the Host(s) and any confirmed Guest(s). However, your billing and payout information will never be shared with another user. If a Guest books an Accommodation for a business trip, and the Guest is engaged or employed by a company or other organisation that is enrolled in our Business Travel Program, we may disclose the name of the Host and the address and other Accommodation information to the Guest’s organisation.
When a Guest stays at your Accommodation or when you stay at a Host’s Accommodation, we may ask you to review the Guest, Host, or the Accommodation. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Guest or Host may be public on the Platform.
You may link your account on a Third-Party social networking site to your TwoCrown Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:
- some of the information you provide to us from the linking of your accounts may be published on your TwoCrown Account profile;
- your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;
- a link to your public profile on that Third-party social networking site may be included in your TwoCrown public profile;
- other TwoCrown users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
- other TwoCrown users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s);
- the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
- the publication and display of information that you provide to TwoCrown through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.
We may distribute parts of the Platform (including your Listing) for display on sites operated by TwoCrown’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
TwoCrown Payments may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom TwoCrown Payments has a formal agreement; and (iii) with respect to information about your transactions and experiences only.
We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (such as Concur and American Express). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
For any jurisdiction in which we facilitate the Collection and Remittance of Taxes or Opt-in for Host Remittance of Taxes as described in the “Taxes” section of the Terms of Service, Hosts and Guests expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, bookings, Accommodations and Occupancy Taxes, including, but not limited to, personally identifiable information such as Host or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Hosts from Guests, or allegedly due, contact information and similar information, to the relevant Tax Authority.
We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
- providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
- we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon TwoCrown’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
In instances where TwoCrown complies with legal requests for user data without notice to the user for the reasons described above, TwoCrown will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
BUSINESS TRANSFERS BY TWOCROWN
HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR TWOCROWN ACCOUNT
You may review, update, correct or delete the Personal Information in your TwoCrown Account. If you would like to correct your information or cancel your TwoCrown Account entirely, you can do so by logging in to your TwoCrown Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your TwoCrown Account is cancelled.
SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
TwoCrown uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.
TwoCrown cookies and Third Party cookies
We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.
Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
Uses for TwoCrown cookies
- to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.
- to simplify your access to and use of the Platform and make it more seamless.
- to monitor and analyse the performance, operation and effectiveness of the Platform, so that we can improve and optimise it.
- to show you content (which may include advertisements) that is more relevant to you.
- for fraud detection and prevention.
Uses for Third-Party cookies
Our partners’ cookies are intended to obtain information to help them provide services to TwoCrown. For example, Third Parties we engage to provide services to us may track your behaviour on our Platform to market and advertise TwoCrown listings or services to you on the Platform and Third-party websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties TwoCrown account.
"Aggregated Information" means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.
"Data Controller" means TwoCrown, the company responsible for the use and processing of Personal Information.
"Personal Information" means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
WHAT TYPES OF INFORMATION DOES TWOCROWN GATHER ABOUT ITS USERS?
Information that you give us
We receive, store and process information that you make available to us when accessing or using our Platform and Services. Examples include when you:
- fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID verification information;
- access or use the Platform, such as to search for or post Accommodations, make or accept bookings, pay for Accommodations, book or pay for any associated services that may be available (such as but not limited to cleaning), post comments or reviews, or communicate with other users;
- link your account on a third party site (e.g. Facebook) to your TwoCrown account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you; and communicate with TwoCrown.